Audit of National Standards

Final Report - July 2021

This report has been reviewed in consideration of the Access to Information Act and Privacy Acts. The asterisks [***] appear where information has been removed; published information is UNCLASSIFIED.

Table of contents

• Acronyms and abbreviations
• Executive summary
• Management's response to the audit
• 1.0 Background
• 2.0 Objective, scope and methodology
  • 2.1 Objective
  • 2.2 Scope
  • 2.3 Methodology
  • 2.4 Statement of conformance
• 3.0 Audit findings
  • 3.1 Policy framework
  • 3.2 Standards development process
  • 3.3 Planning and implementation
  • 3.4 Oversight and monitoring
• 4.0 Conclusion
• 5.0 Recommendations
• Appendix A – Audit objective and criteria
• Appendix B – Management action plan
• End notes

Acronyms and abbreviations

C&IP

Contract & Indigenous Policing

CM&C

Corporate Management and Comptrollership

CO

Commanding Officer

ERT

Emergency Response Team

IAER

Internal Audit, Evaluation and Review

IARD

Immediate Action Rapid Deployment

HRMIS

Human Resource Management Information System

L&D

Learning & Development

NHQ

National Headquarters

OAG

Office of the Auditor General

OM

Operational Manual

RCMP

Royal Canadian Mounted Police

RBAEP

Risk-based Audit and Evaluation Plan

RM

Regular member

SEC

Senior Executive Committee

SMT

Senior Management Team

TEAM

Total Expenditures and Asset Management System

Executive summary

Organizations create standards to provide employees with agreed upon expectations for how work will be done and to enable people to work together. In the policing context, national standards generally establish the minimum requirements that police officers must meet in a given area of operations. In order for the Royal Canadian Mounted Police (RCMP) to determine what national standards are necessary to support operations, a comprehensive development process needs to be in place.

Accordingly, the Commissioner approved the Audit of National Standards as part of the 2019-2024 Risk-Based Audit and Evaluation Plan. The objective of the audit was to assess the adequacy of the process in place to develop and implement national standards in relation to ongoing and emerging operational needs. The scope of the audit focused on the development, implementation, and monitoring of national standards in relation to officer safety between January 2015 to December 2019.

The audit found that a process to develop national standards exists, but that this process is not always followed. In addition, the need to develop national standards for the Force has not been documented, nor are standards defined to illustrate how they would complement the existing RCMP policy framework. A central roll out plan was not in place to support the implementation of existing standards, which resulted in divisions experiencing challenges in conducting the training necessary to meet the standards. Finally, key elements of life cycle management were not in place in the RCMP to ensure that divisions could purchase and maintain the equipment needed to comply with the standards.

The audit found that monitoring and oversight mechanisms for existing standards were in place to monitor compliance, but corporate data was not accurate and not consistently validated across divisions. Oversight could be strengthened to resolve issues impeding monitoring and compliance across the organization.

Opportunities exist to formally define the term national standards, determine the role of national standards in the RCMP policy framework, and strengthen the standards development process. The implementation of existing standards provides valuable lessons learned to inform the way forward for any future development of national standards for the RCMP. The review of existing standards will help ensure that objectives are attainable and can be met.

The management response and action plan developed in response to this report demonstrate the commitment from senior management to address the audit findings and recommendations. RCMP Internal Audit will monitor the implementation of the management action plan and undertake a follow-up audit if warranted.

Management's response to the audit

Overall, we agree with the findings in the Audit of National Standards and accept all the recommendations contained within. OM – ch. 99.1 and 99.2 were the first operational standards to be developed under this framework and were based on pre-existing ERT training requirements and driven by recommendations from the 2014 Moncton Shooting Independent Review (MacNeil Report), respectively. We appreciate Internal Audit, Evaluation and Review's focus on these initial operational standards, as it helps ensure that we establish the necessary foundation and are on the right track for the future.

The audit identified several important areas and opportunities for improvement, many of which, we have already taken significant steps towards adopting. For instance, in 2019/2020, concurrent to the audit and outside scope period, we undertook a full re-write of OM – ch. 99.2. During this revision, we systematically followed the operational standards development process and strengthened the consultative and planning phases. Our approach addressed many of the deficiencies outlined in the audit and helped improve the successful implementation of an achievable and sustainable operational standard. However, as recommended in the audit, we will evergreen the operational standards development process to better define roles and responsibilities of committees and stakeholders involved in the process. We will also continue to work with our partners in Procurement, Materiel and Asset Management, Learning and Development, and other key areas to formalize requirements for central planning and supporting strategies. Additionally, we will update the development process to align with the new RCMP Governance Committee Framework and seek to implement a standing committee, charged with overseeing the development of operational standards.

We look forward to working with our partners, key stakeholders, and the Senior Executive Committee (SEC) to modernize the evidence and risk-based process for identifying and prioritizing areas that require the development of operational standards. This will facilitate an annual assessment of where national standards are required for the Force.

As part of the Vision150 Modernization initiative and policy renewal initiative, we aim to better define the role of operational standards and how they complement existing policies. As the audit outlines, this will help ensure that all employees understand the roles and expectations of this instrument. We have also recently taken steps to communicate this information to RCMP employees. For example, we accompanied the December 2020 update to OM – ch. 99.2 with a force-wide communiqué to the membership, as well as to CROPS and Commanding Officers, which outlined the role and purpose of operational standards.

Lastly, we will continue to monitor progress on these operational standards. This will help ensure that objectives are attainable and address divisional challenges related to non-compliance.

We look forward to continuing to strengthen this framework to ensure operational standards are drivers of police service delivery and focus on key officer safety issues. We will continue to look to this audit and its recommendations to guide us through this endeavour.

Deputy Commissioner Brian Brennan, Contract and Indigenous Policing

1.0 Background

Organizations create standards to provide employees with an agreed upon expectation for how work will be done and to enable people to work together effectively. Standards can cover a wide range of activities such as defining equipment specifications, managing a process, delivering a service, supplying materials, or delivering training.

The RCMP Operational Manual (OM) contains national standards, which consist of four investigative standards ^{Endnote 1} and two operational standards ^{Endnote 2} . In addition, the Administration Manual (AM), the OM and subsidiary manuals (collectively referred to as the "Manuals") contain policies that may have standards embedded within them and that may be considered national in scope when they must be followed by employees.

In the policing context, officer safety is a key factor driving the development and implementation of national standards. Officer safety is a priority for the RCMP due to the inherently dangerous nature of police work as Regular Members can be injured in the course of their regular duties or in extraordinary circumstances such as active shooter situations. Part II of the Canada Labour Code requires that the RCMP demonstrate due diligence to prevent workplace injuries ^{Endnote 3} .

In 2019, the Office of the Auditor General (OAG) published the Audit of Equipping Officers of the RCMP, which examined whether RCMP officers had the equipment and training required to perform their duties safely. The OAG found that the RCMP did not have national standards regarding the availability and deployment of carbines ^{Endnote 4} and hard body armour across the organization. The OAG also found that the RCMP did not have the necessary information at the national level to determine whether detachments across the country had enough protective equipment to meet the RCMP's obligations under the Canada Labour Code ^{Endnote 5} .

In response to the OAG audit, the RCMP agreed to develop additional standards that move towards all operational frontline members being trained on the patrol carbine and being personally assigned hard-body armour, and that move towards one long-gun ^{Endnote 6} per operational vehicle. This audit includes references to the OAG audit findings where they provide context and contribute to the RCMP Internal Audit, Evaluation and Review (IAER) current audit assessment of national standards.

The RCMP's Commissioner-approved 2019-2024 Risk-based Audit and Evaluation Plan (RBAEP) included an Audit of National Standards, with a focus on assessing the adequacy of the process in place to develop and implement national standards in relation to ongoing and emerging operational needs.

2.0 Objective, scope and methodology

2.1 Objective

The objective of the audit was to assess the adequacy of the process in place to develop and implement national standards in relation to ongoing and emerging operational needs. Appendix A presents the audit objective and criteria.

2.2 Scope

The scope of the audit included the development, implementation, and monitoring of national standards in relation to officer safety. In addition, the audit reviewed other standardization initiatives underway at the time of the audit. The scope period was January 2015 to December 2019. The analysis included selected training data to March 2020 to reflect the most current results. An assessment of the standards' validity was not included in the audit scope.

2.3 Methodology

The term "national standards" is currently not used officially in the RCMP Manuals. According to Contract and Indigenous Policing (C&IP), operational standards OM – ch. 99.1 and 99.2 are national standards, as they contain clear training or equipment requirements that must be implemented by all divisions. As such, the audit team examined operational standards OM – ch. 99.1 and 99.2 to assess whether an adequate process was in place to develop and implement national standards.

OM – ch. 99.1 Emergency Response Teams (ERT) – Maintenance Training identifies the mandatory training requirements that ERT members must complete monthly, along with training required for specialized profiles to maintain proficiency in these areas. OM – ch. 99.2 Mandatory Training: Active Threats identifies the mandatory training requirements for Immediate Action Rapid Deployment (IARD) and the patrol carbine that operational frontline RMs must complete.

Planning for the audit was completed in February 2020. In this phase, the audit team conducted interviews, process walkthroughs, and examined relevant policies, procedures and results of previous audit work performed. The examination phase was completed in October 2020, and employed various auditing techniques including interviews, documentation reviews, and data analysis. Site visits took place at three divisional headquarters (E, K, and M divisions) to assess practices and processes. In addition, a random sample of [***] ERT members from five divisions (B, E, K, M, National) was drawn to assess member compliance with each course requirement included in OM – ch. 99.1. Upon completion of the examination phase, the audit team held meetings to validate findings with key personnel and debriefed senior management on the relevant findings.

Given the lack of clear definition for the terms national standards and operational standards, these two terms are used interchangeably in the audit report. The requirements associated with OM – ch. 99.1 and 99.2 are referred to as "existing standards" for the purpose of this report.

2.4 Statement of conformance

The audit engagement conforms to the Institute of Internal Auditor's International Professional Practices Framework and the Treasury Board of Canada Directive on Internal Audit, as supported by the results of the quality assurance and improvement program.

3.0 Audit findings

An adequate process is necessary to ensure that national standards are developed based on evidence, and that they achieve intended objectives. Such a process, supported by a sound governance structure, would support the RCMP in establishing national standards that contribute to improving officer safety. Accordingly, the audit team expected to find:

• An assessment of needs regarding the establishment of national standards
• A definition of national standards and a description of how they complement existing policies
• A documented process defining roles and responsibilities for all stakeholders involved
• A comprehensive list of mandatory consultation, a requirement for evidence-based research and a detailed approval process to support the development of national standards
• The development of national roll-out plans or strategies taking into consideration resources, training, equipment, and life cycle management requirements to ensure the successful implementation of standards by divisions
• A reporting and monitoring mechanism defining responsibilities and expectations, as well as engagement with divisions to address any organizational issues

3.1 Policy framework

The RCMP primarily uses its Manuals to provide guidance to employees and ensure officer safety. The Manuals include investigative and operational standards, national policies, and divisional policies. The audit expected standards to be well-defined and to complement existing RCMP policies.

The AM – ch. III.4. Manual System states that all RCMP directives must be published in the official manual system, which consists of the AM and OM and their corresponding subsidiary manuals. It also notes that failure to do so can cause great confusion and could result in legal ramifications where the RCMP is challenged to explain its practices ^{Endnote 7}. For the purpose of the manual system, the term directives means both policies and procedures. Policies are defined as the general principles by which the RCMP is guided and directed in the management, administration and fulfillment of its programs and services as authorized by laws, regulations and rules ^{Endnote 8}. Procedures are defined as the actual courses of action, methods, steps, and routines, to be followed in accordance with the guiding policies, laws, regulations and rules ^{Endnote 9}.

While the OM contains four investigative standards and two operational standards, the audit did not find a definition of standards in the Manual. The RCMP's Information Management Branch Policies and Publications Section noted that the Treasury Board defines "standards" as "a set of measurable operational or technical specifications that can also include the detailed steps required to perform a task." However, this definition has not been approved and communicated across the RCMP.

The audit team also did not find guidance to define or explain the term operational standards. When the Senior Executive Committee (SEC) approved operational standards OM – ch. 99.1 and 99.2 in 2017, it was advised that operational standards would be a vehicle to highlight existing requirements or create new ones that are considered critical to organizational priorities, such as police and public safety. However, a definition was not provided to be included in the Manuals to clarify the use of the term 'operational standards'.

Finally, there was no guidance to clarify the difference between policies and standards. The audit observed that the difference between operational standards and policies was not well-understood by interviewees across business lines and in divisions. Interviewees frequently could not differentiate standards from policies, or what the threshold for developing standards was. While several interviewees perceived policies as guidance and standards as mandatory, others thought the terms were interchangeable. Some interviewees were not fully aware of whether the Force had national standards. Placing national standards within the OM, alongside policies, created further ambiguity as to whether these standards were mandatory across the Force.

Given that national standards aim to establish a minimum requirement to be met across the Force, it is necessary that they are clear, concise, and contain measurable performance metrics. A consistent format for national standards would help to ensure that they are easily recognizable by members across the Force. The difference between policy and standards needs to be well-understood, along with the expectation for mandatory compliance.

As part of the Vision150 Modernization initiative, the RCMP committed to conduct a policy renewal, which intends to review all policies in the Manuals, and define what is a policy, guideline, standard, and procedure. In so doing, there is an opportunity for the RCMP to develop documented definitions of national standards, and to determine how national standards complement existing policies. Communicating these definitions across the organization would ensure that all employees understand the expectations attached to each instrument and use them consistently.

Need assessment

In recent years, several reports and fatality inquiries have highlighted the need to standardize equipment and training for RCMP members, or have made recommendations to reduce risks to officer safety. The Canada Labour Code Part II stipulates that every employer shall ensure that the health and safety of every person employed is protected at work, meaning that the RCMP must take the necessary steps to ensure the safety of all employees at all times ^{Endnote 10} . As such, the audit expected the RCMP to have assessed the need for national standards, as well as identified the most important areas that warrant national standards in accordance with organizational priorities and health and safety obligations.

In 2014, three RCMP RMs were killed in the line of duty during an active shooter incident in Moncton, New Brunswick. An investigation resulted in a Canada Labour Code prosecution of the RCMP, and a conviction in 2017 for failing to provide appropriate use of force equipment, training and supervision to officers when responding to an active shooter event ^{Endnote 11} . The 2014 Moncton Shooting Independent Review (MacNeil Report) highlighted the fact that the RCMP did not have a national standard in place for the number of carbines that should be maintained within each division ^{Endnote 12}.

In response to these events, C&IP presented the standards development process to SEC in 2016, which initiated the approval and development of national standards for the Force. A briefing note to the Deputy Commissioner of C&IP confirmed in 2017 that C&IP's Operational Research Unit had developed a methodology for developing standards, and that this unit would be responsible for identifying areas where standards may be required for the Force. The audit found that C&IP had developed a list of potential areas that warranted operational standards related to:

• mandatory training (lethal force, critical incidents, hard body armour, firearm qualification, carbine)
• mandatory equipment (radio, geographic location tracking, night goggles, GPS tracking, carbine)
• plans (emergency operational plans, standard operating procedures for operational call out)

The presentation made to SEC in 2016 stated that operational standards would contribute to member wellness and safety, ensure that Canada Labour Code standards are complied with, and provide clear cost justification to policing partners. SEC was advised that standards would be a vehicle to identify requirements that are considered critical to organizational priorities. At the period of the reporting phase of the audit, two operational standards have been approved in the RCMP.

The audit did not find evidence of documented analysis to support why national standards were required in these potential areas. Criteria were not established to define why these areas should be subject to national standards instead of policies and how they relate to organizational priorities. Further, there was no evidence that key factors that could drive the development of standards, such as inquiries, changes to legislation, court rulings, and health and safety incidents, had been assessed to determine whether standards should be developed as a result.

Finally, there was no evidence that the impact of establishing national standards had been assessed, or that a strategy had been developed to address non-compliance. Adopting national standards without assessing the impact, commitment, and likelihood of compliance increases the risk that the organization will be unable to comply with them, which could impact officer safety.

In conclusion, the term national standards is not well-defined. There is an opportunity to define how national standards complement existing policies within the context of the Vision150 Modernization policy renewal initiative. In addition, the audit did not find evidence of a documented analysis to determine areas where national standards are required in addition to current policies to support critical organizational priorities and to enhance officer safety. Without undertaking an analysis to determine areas in which the RCMP needs national standards, there is a risk that standards may be developed in an ad hoc manner and may not be achievable. There is an opportunity to review the areas within the RCMP that warrant national standards.

3.2 Standards development process

The audit expected to find an approved process in place for the development of national standards that includes requirements for evidence-based research, consultation, and approval. It also expected to find that roles and responsibilities for all stakeholders involved in the process are clearly defined.

Although the RCMP has not defined how national standards complement existing policies, the audit found that C&IP established and documented a process for the development of standards, which was approved by SEC in 2016. This process involves a three-phase approach, which covers requirements for the planning, development, and approval of national standards.

The planning phase requires C&IP to:

• perform a review of recommendations from inquiries, external bodies, internal reports, occupational health and safety reports, statistics, and operational data
• identify areas where national standards may be needed and score each area using a scorecard to prioritize the topics for the development of standards
• prepare an annual action plan with options to develop standards each year
• present the action plan to SEC to obtain a decision on which standards to prioritize for development in the coming year.

The development and consultation phase identifies the steps required when drafting standards, such as outlining the research, analysis, and consultation to be undertaken. Consultations should involve different stakeholders across several business lines and divisions, including Depot, Occupational Health and Safety Branch, the Strategic Policing Agreements section of C&IP, and Learning & Development (L&D). This phase also states that a financial implications analysis is required to be performed prior to new standards being approved. These requirements are identified in a standards development tool.

Lastly, this process outlines the approval phase requirements for standards, which include review by the National Integrated Operations Council, Senior Management Team (SMT), and SEC before being presented to the Commissioner for final approval.

The audit examined whether the key steps of the development process were followed when OM – ch. 99.1 and 99.2 were developed. Testing results are found in the table below.

While the audit found evidence that the key steps of the process had been followed, it noted some gaps and deficiencies. First, the audit did not find evidence that the planning phase prioritization approach had been implemented by C&IP. While the topic of national standards was discussed at SEC and SMT between 2016 and 2020, an action plan with priorities was not prepared and presented to SEC for approval annually.

Second, some of the research identified in the development and consultation phase was either not performed or not documented during the development of OM – ch. 99.2. While the costs of implementing existing standards were discussed with divisions and contract partners, there was no evidence that a financial implication analysis had been performed to address any funding limitations prior to their final approval.

In addition, the standards development process identifies a list of units to be consulted, but does not define the roles and responsibilities of units and committees involved in the development process. Given that national standards apply to the organization as a whole, consulting other business lines early in the process is key to ensuring buy-in and future compliance. While some consultations with stakeholders were conducted during the development of OM - ch. 99.1 and 99.2, there was no documented evidence to indicate that all key stakeholders were consulted early in the process, and that divisional constraints and challenges had been considered. Interviewees at the divisional level responsible for implementing the standards associated with these chapters noted that they were not involved early in the process in order to identify challenges and constraints related to planning, equipment, and training.

In conclusion, C&IP developed a standards development process for the RCMP outlining research, consultation, and approval requirements. However, some of the key elements of the development process were not performed when existing standards (OM - ch. 99.1 and 99.2) were drafted. In addition, roles, responsibilities, and accountabilities for the development of national standards were not well defined. Without clearly communicating the national standards process to key stakeholders, and following it systematically, there is a risk that implementation challenges may not be addressed in a timely manner.

3.3 Planning and implementation

Implementing new national standards related to training or equipment requires significant effort and resources. As such, we expected that national rollout plans would be in place that take into consideration resources, training, equipment, and maintenance requirements. We also expected to find evidence of the development of funding strategies to support the implementation of national standards, and the coordination of funding for life cycle requirements including facilities, training, and ongoing maintenance.

Planning and Implementation

The audit found that the implementation of existing national standards was done divisionally rather than organization-wide. The SEC decision to approve the decentralized implementation of OM – ch. 99.1 and 99.2 resulted in divisions being responsible for procuring equipment and rolling out training for their members once these OM chapters had been approved.

The 2019 OAG audit found that the RCMP did not have a plan for procuring carbines to ensure that its officers were adequately equipped. Rather, the decision-making related to this was delegated to divisions and detachments ^{Endnote 13} . The IAER audit team assessed whether C&IP provided guidance to divisions to assist in the implementation of OM – ch. 99.1 and 99.2. The audit noted that a plan had not been developed prior to the rollout of OM – ch. 99.1 (ERT training). While a risk assessment tool was provided by C&IP to divisions to assist them in determining the number of carbines needed to meet standard OM – ch. 99.2, it was not sufficient to support the divisional rollout.

In addition, the audit did not find evidence of analysis of the financial impacts that these new standards would have on divisions. Nor were funding strategies developed to address cases where divisions or contract partners would not be in a position to fund the new requirements. Corporate Management & Comptrollership (CM&C) confirmed that [***] for the implementation of OM – ch. 99.1 and 99.2, and that [***] Instead, divisions were required to fund the implementation of these standards from existing budgets [***] The [***] jurisdictions, which impacted the timeline for the rollout. For example, [***]

Divisional interviewees identified several factors that should have been taken into consideration prior to the implementation of OM – ch. 99.1 and 99.2, including the need for funding, appropriate assets (e.g. ammunition, holsters, and storage facilities), training facilities, instructors and realistic timelines. Interviewees also noted that divisions experienced challenges finding training facilities, purchasing equipment, and identifying resources to work overtime to meet the required timelines and compliance levels. Some of these challenges still exist today, such as [***]

An implementation plan taking into consideration resources, training, equipment, and maintenance could have served as a guide to ensure a coordinated and consistent effort among divisions. A coordinated planning effort along with a funding strategy could also have contributed to cost efficiencies and more effective implementation.

Equipment and Life Cycle Management

The RCMP has a number of equipment requirements for firearms, uniforms, and intervention equipment embedded in its policy manuals. Some of these policies prescribe specific requirements (makes, models, and specifications), while others are less prescriptive and serve as guidelines. While these policies are not identified as national standards, they describe the approved equipment for the Force. National standards can also include equipment requirements, such as the need for detachments and units to have carbines available for frontline officers (OM – ch. 99.2).

In regards to equipment, the audit expected the standards development process to take into account life cycle management for equipment. Furthermore, the audit expected that roles and responsibilities for all units involved in the planning, purchase, delivery, maintenance, and disposal of equipment would be clearly defined to ensure that the capabilities defined in national standards could be met.

Similar to the 2019 OAG Audit, which found that the RCMP had not considered all of the life cycle stages of the carbine project ^{Endnote 14}, the IAER audit found that the standards development process does not include considerations for life cycle management of equipment. The audit team did not find evidence that life cycle materiel management had been considered systematically prior to implementing existing standards.

The lack of planning for life cycle management resulted in the implementation of OM – ch. 99.2 having a significant impact on RCMP armouries, training facilities, detachments and procurement units. It also resulted in divisions adopting different materiel management practices. During site visits, divisional interviewees identified that they experienced challenges related to life cycle management such as defining their carbine needs, developing cost estimates, communicating the need to policing partners, obtaining approval for timely delivery of equipment, and obtaining funding for procurement of the equipment. Divisions also experienced challenges with the maintenance and storage of the equipment procured to comply with the standard.

While several stakeholders were involved in the development of equipment standards, the audit found that the responsibility for life cycle management had not been assigned organizationally. Units such as C&IP, Materiel Assets, Uniform and Equipment, and Procurement and Contracting were involved in the development of equipment standards for uniforms, firearms, operational and communication equipment. Governance committees, such as the Operational Equipment Oversight Committee created in 2015, also discussed equipment acquisition and maintenance. However, there was no unit mandated to perform the ongoing life cycle management of operational equipment on a Force-wide basis.

In 2018, the RCMP assessed the concept of a Chief of Program to identify, plan, and manage investments for equipment related to core RCMP capabilities. [***] This would serve to minimize the challenges associated with procurement and maintenance in a decentralized organization. However, the initiative was not in place at the time of the audit. The audit found that the absence of a unit responsible for life cycle management across the RCMP impacted the successful implementation of national standards, where planning and identifying the investment needed for equipment is critical to compliance as well as enhancing officer safety.

The lack of planning for life cycle management presents a risk that equipment will not be managed effectively and efficiently, potentially resulting in members not having the equipment they need. In 2017, the RCMP was convicted under the Canada Labour Code for failing to provide appropriate use of force equipment, which in part highlighted the need for life cycle management on a Force-wide basis. Failure to consider life cycle management during the development of national standards could also increase the risk that costs associated with the implementation of national standards are under-estimated. This may result in divisions not having sufficient funds to procure and maintain equipment required to comply with national standards.

Training

National standards often include initial and ongoing training for members. As such, the audit expected that the standards development process would include consideration for training infrastructure, resources, materiel, and ongoing investment for recertification required over time. The audit found that the following units were involved in the development and delivery of mandatory training in the RCMP: L&D at NHQ, including the National Tactical Training Unit; training units in divisions; Depot (T Division); regional training facilities such as the Pacific Region Training Centre; and the National Mandatory Training Oversight Sub-Committee.

As part of the roll out for national standards OM - ch. 99.1 and 99.2, the RCMP adopted a decentralized approach, which meant that C&IP was responsible for developing standards while divisions were responsible for funding and rolling out any new training initiatives that were part of the standards. Similar to the challenges with equipment previously mentioned, interviewees identified that the development of training standards appeared to be ad hoc, and had not considered the key elements to support the rollout of training required by OM – ch. 99.1 and 99.2 prior to implementation.

This decentralized approach resulted in challenges across the divisions such as difficulties with securing funding for training facilities; training new instructors to deliver courses; procuring ammunition, holsters, and storage facilities to secure training assets; and delivering training to meet the timelines. A national strategy could have improved the consistency and timeliness of training across divisions. It could also have provided an opportunity to achieve cost efficiencies.

Compliance with Training Requirements

OM – ch. 99.1 (ERT Training)

The audit team examined whether divisions complied with the training requirements included in OM – ch. 99.1 for the period January 2018 to June 2019. The standard requires 40 hours of basic training per month per ERT member, to be reported to C&IP twice a year in January and July (240 hours of training per six-month period per ERT member). The table below identifies the average number of training hours completed per member included in the sample for each period.

The audit found that basic training hours varied across periods for all divisions. The overall average number of basic training hours performed per ERT member in our sample was 562 hours. This was below the 720 hours required by the standard (40 hours x 18 months = 720 hours per ERT member). [***]

Compliance with the required 40 hours of training per month was impacted by several factors. Interviewees stated that operational requirements in divisions, as well as leave and injuries, prevented ERT members from meeting training requirements. Interviewees also mentioned that in some divisions training days were sometimes used by ERT members to complete administrative tasks, further impacting the number of training hours performed by each member.

The audit also found that compliance with specialized training requirements included in OM – ch. 99.1 varied across divisions^{Endnote 15}. While some divisions had a few individuals trained in every specialty, other divisions concentrated their training efforts in a few specific areas. Some interviewees questioned the need for all ERTs to have the same specialized training and functionality, suggesting that a risk-based approach may be more practical and reasonable. For example, the need for marine operation training may not be relevant in divisions that have no access to oceans or other large bodies of water.

The inability of ERTs across the Force, either part-time or full-time, to meet the training requirements included in the standard may indicate that the standard is not achievable or, alternatively, oversight is lacking to ensure that the standard is met.

OM – ch. 99.2 (IARD training)

The audit team also examined compliance with OM – ch. 99.2, which requires that operational members complete the four IARD courses listed in the table below. Operational members are defined as those members with RCMP medical profiles 1 and 2, which indicates that they are physically and mentally fit to perform all the tasks of a general duty constable in a manner that does not jeopardize his/her safety, or that of coworkers and the public^{Endnote 16} . The audit team examined IARD training data for the period 2016 to 2020 in order to assess whether compliance was met.

As written, OM – ch. 99.2 requires that 100% of operational members complete each of the four IARD courses once in their career. The audit found that none of the divisions had reached full compliance with this standard. All divisions had trained more than 80% of their operational members in each of the four IARD courses, with the majority having reached 90% as indicated in Table 3. Rank had an impact on course completion, with Superintendents and above having the lowest compliance rates.

OM – ch. 99.2 (Carbine Training)

OM – ch. 99.2 also required that divisions have 65% of frontline operational RMs trained in the use of the patrol carbine by March 31, 2018. C&IP defined frontline members based on 22 specific job codes, which included detachment supervisors, traffic services, police dog handlers, and investigators.

The 2019 OAG Audit previously found that the RCMP had met its target of having 65% of frontline operational members trained on carbine by March 31, 2018, but 13% of these members had not completed the annual recertification training at the time of the audit ^{Endnote 17}. The IAER audit tested compliance as of January 2020 to ensure that the standard continued to be met. Results are found in the table below.

The IAER audit found that contract divisions continued to exceed the 65% requirement. However, [***] In addition, OM – ch. 99.2 refers to the requirement to comply with OM – ch. 4.15 Patrol Carbine policy, which states that members qualified to use the carbine must recertify within 12 months of previous qualification to carry the carbine operationally ^{Endnote 18}. While, contract divisions exceeded the standard of having 65% of their frontline members trained as at January 2020, a significant percentage of these members did not comply with the 12-month recertification requirement. [***]

In conclusion, the lack of central planning to support the rollout of training resulted in divisions experiencing significant implementation challenges. While compliance rates with existing standards (ERT, IARD, carbine training and recertification) were high, no division was able to achieve full compliance with ERT and IARD training requirements. Without guidance and national strategies in place, there is a risk that divisions may roll out training inconsistently and acquire equipment that they cannot support throughout the life cycle. The development of national standards should rely on strong planning to ensure their successful implementation and the reduction of risks to officer safety.

3.4 Oversight and monitoring

Monitoring

Accurate and timely information is essential to enable the monitoring of national standards to ensure compliance and consistency across the organization. The audit expected that a monitoring and reporting mechanism would be included in existing national standards along with access to accurate and timely information for monitoring compliance.

According to standards OM – ch. 99.1 and 99.2, C&IP is responsible for monitoring compliance at the national level while divisional Commanding Officers (COs) are responsible for implementing the standards and ensuring compliance at the divisional level. This responsibility is often delegated to a division's Criminal Operations Officer and the District Administrative Non-Commissioned Officer, who monitor training at the divisional or district level.

Several corporate systems are used to collect, transmit, and analyze compliance data. For example, IARD and carbine data is extracted from the Human Resource Management Information System (HRMIS) and the Total Expenditures and Asset Management System (TEAM). C&IP then uses statistical and geographic location tracking technologies to aggregate and present carbine data in the form of compliance maps. ERT data is collected by divisions using spreadsheets and local databases. The information is then summarized in templates developed by C&IP and sent to the Critical Incident Program within C&IP twice a year.

While data is gathered and sent to C&IP as per the requirements, the audit found some deficiencies with the collection, aggregation, and presentation of data. For example, the templates in place to report ERT training data were not designed to allow C&IP to aggregate the data and develop meaningful reports for monitoring. This was especially true for data on specialized training. Similar to the OAG Audit, which found that corporate data did not allow the RCMP to have an accurate picture of where carbines were located at the detachment level ^{Endnote 19}, the IAER audit noted some limitations with data extracted from corporate systems. For example:

• Data was not always updated in a timely manner in HRMIS and TEAM
• Collator codes used to record equipment within TEAM were not always used consistently which prevented access to the exact location of carbines
• The use of location codes to map compliance data presented limitations due to members working off-site temporarily or permanently away from their units

C&IP improved the compliance maps in October 2018 to provide electronic, interactive maps to better monitor carbine distribution and training within the divisions. The IAER audit reviewed the data and maps produced in January 2020 and found that maps produced by C&IP may not depict an accurate picture of the situation at the detachment level and indicate whether divisions complied with the standard. C&IP is aware of the data limitations and conducts manual interventions to improve the accuracy of the data. While C&IP relies on divisions to validate the information shown on the maps, interviewees at the detachment level informed the audit team that they do not consistently receive the maps from divisional headquarters and do not always have data available to validate them.

Compliance and oversight

An oversight function is essential to provide ongoing guidance and address deficiencies in the standards process in a timely manner. The audit expected that oversight would be in place to ensure compliance with standards, that issues were resolved and that the objectives of the standards were met.

Oversight

OM – ch. 99.1 requires that ERT leaders conduct a review and determine whether ERT members meet the 40-hour basic training requirement per month. ERT leaders are required to complete and send a report bi-annually to the divisional CO, as well as C&IP, which is responsible for identifying trends, issues, and opportunities for improvement.

While the audit saw evidence that compliance was monitored and issues were raised by divisions, there was no evidence that C&IP documented issues, identified opportunities for improvement and suggested changes to existing practices to improve compliance nationally. Rather, evidence suggested that ad hoc discussions were occurring with individual divisions, and that strategies were identified to solve challenges at the divisional level rather than organizationally. [***] Similarly, establishing a full-time ERT in every division has been proposed as an organization-wide solution in the RCMP 2019 ERT Modernization Review but is still under discussion ^{Endnote 20}.

OM – ch. 99.2 states that the identification of issues, trends, and measures to improve compliance is the responsibility of C&IP and divisional COs. The standard states that C&IP is required to track the results of mandatory training compliance nationally (for carbine and IARD) to identify trends, and send a report annually to divisional COs. The CO should in turn, analyze the report provided by C&IP to identify issues and opportunities for improvement.

The audit noted that issues and challenges were raised by divisions in regards to compliance with OM – ch. 99.2. For example, divisional interviewees highlighted issues that prevented compliance with IARD and carbine training requirements [***] However, the audit found no evidence that actions have been taken to correct these issues organizationally. Addressing issues and challenges organizationally will be necessary to ensure that compliance with national standards can be met and risks to officer safety are minimized.

Achieving objectives

In addition to measuring compliance against existing standards, the audit assessed whether the standards were written in a way to reduce risk to officer safety and increase readiness to respond to ERT and IARD events. Evidence-based requirements and clear performance metrics are required to ensure that national standards are met. The audit noted that OM – ch. 99.1 includes performance targets for each training requirement. However, evidence was not available to support the reason for selecting the number of training hours for each ERT course, and to explain how these requirements would translate into a state of readiness for ERTs across the Force. Given that no part-time or full-time ERT met the training standard in the last two years, there is an opportunity to review the requirements, obtain evidence-based information to determine whether the standard is appropriate, and ensure that the objective of the standard is being met.

OM – ch. 99.2 has a clear target for carbine training – that 65% of all frontline members be carbine trained by March 31, 2018. However, evidence was not available to support the basis for selecting the 65% target, and assessing compliance at the divisional level as opposed to the detachment level. In response to the 2019 OAG Audit recommendation that the RCMP establish a national standard to ensure that each detachment is adequately equipped with carbines, C&IP revised OM – ch. 99.2. The IAER audit noted that the revision, which is still in draft, will amend the 65% divisional target for carbine training and increase it to 90% in each detachment in a phased approach over five years, reaching full implementation in 2025. The audit reviewed the draft revision and noted the following:

• The definition of frontline officers was amended to include 31 job codes that reflect both Contract and Federal Policing positions. However, job codes may still not be aligned with actual duties performed and may not capture all members occupying positions that require the use of the patrol carbine.
• The draft revision includes a caveat stating that operational realities may pose challenges to meeting the benchmarks in the standard. The inclusion of such a caveat could provide a justification for not meeting the standard and may impact rates of compliance.
• The revision requires that divisional COs develop supplemental policy to identify positions that are not captured in the frontline job codes. This may result in divisions having different carbine capabilities, which would increase the risk of non-conformity to a national standard.

The audit identified that divisions experienced challenges in achieving the 65% standard. As such, consideration should be given to the development of a national strategy to mitigate previous implementation challenges to ensure that the Force can meet the revised 90% national standard. Finally, the 2017 Court decision related to the Moncton shootings criticized the RCMP for the pace at which it rolled out carbines to frontline members. Given the unpredictable nature and occurrence of active shooter events, a phased implementation of the new targets over five years could increase the risk that the level of operational readiness may not be sufficient across the RCMP. It may also increase reputational and legal exposure should an active shooter event occur during this time-period.

In summary, the audit found that a monitoring system is in place to measure and report on compliance against the requirements included in existing national standards. However, data integrity issues in corporate systems continue to prevent the monitoring system from depicting an accurate picture of compliance across the Force. As such, the audit found that there are opportunities to improve data accuracy and completeness. Relying on information that is inaccurate and not validated can impact decision-making related to training and equipment for national standards.

In addition, some issues that have been identified as impeding compliance with existing standards have not been addressed organizationally. C&IP has not yet performed a review of OM – ch. 99.1 to assess whether the training requirements translate into a state of readiness for ERTs across the Force. A draft revision of OM – ch. 99.2 is in progress, but opportunities for improvement have been identified to reduce potential negative impacts on compliance. There is an opportunity to revise the standards to ensure that compliance benchmarks are clearly aligned with the expected results, and based on research and industry standards.

4.0 Conclusion

In the policing context, national standards establish the minimum requirements that RCMP members must meet in a given area of operations. As such, a comprehensive development process would support the implementation of national standards to enhance officer safety.

The audit found that the process to develop and implement national standards could be strengthened. This includes the identification of constraints and challenges that impact the implementation of standards, a requirement to identify a funding source for the rollout of standards, conducting comprehensive consultations, and defining roles and responsibilities.

Opportunities for improvement include assessing areas of need for national standards, defining the term national standards, and determining how standards will complement existing policies within the context of the Vision150 Modernization policy renewal initiative. In addition, ensuring that a rollout plan is in place to support implementation of national standards that takes into consideration resource needs, training, and equipment would ensure a coordinated effort across divisions. In particular, planning for the life cycle management of equipment would increase the likelihood of successful implementation and compliance with national standards. Further improvement opportunities exist to validate data to monitor compliance and provide oversight to resolve issues impeding compliance across the Force.

The implementation of existing standards provides valuable lessons learned to inform the way forward for any future development of national standards for the RCMP. Key elements to support the development of standards include developing a national implementation strategy, securing the funding required, and confirming plans with contract partners. Without addressing these factors, the standards development process may not be able to support divisional implementation and address planning, equipment, and training challenges that may arise.

5.0 Recommendations

1. The Deputy Commissioner, Contract and Indigenous Policing should conduct an evidence-based assessment of where national standards are required for the Force, define the use of standards in the context of the RCMP policy framework and develop a communication plan to clarify the difference between national standards and policies to employees.
2. The Deputy Commissioner, Contract and Indigenous Policing should amend the standards development process to include a requirement to:
   1. Define the roles and responsibilities of units and committees involved in the process
   2. Initiate early consultation with key unit, divisional and detachment stakeholders, document and address feedback
   3. Develop national strategies to identify the resources, training and equipment needed to support the implementation of standards across divisions
   4. Adopt a life cycle approach to implementation that includes needs definition, planning, purchase, delivery, maintenance, and disposal of equipment as part of the national strategies
   5. Identify funding needs to implement standards, divisional financial constraints, and mitigation strategies prior to adopting the standards
3. The Deputy Commissioner, Contract and Indigenous Policing should review existing standards to ensure that objectives are attainable, specifically:
   1. Assess and document whether the OM – ch. 99.1 performance targets for training require revision
   2. Assess and document whether the OM – ch. 99.2 use of supplemental policy and caveat will support compliance with the revised national standard

Appendix A – Audit objective and criteria

Appendix B – Management action plan

Date modified:

2021-11-19